Category Archives: Massive increase in crude-by-rail

IMMEDIATE BAN ON DOT-111 tank cars: Crude-By-Rail Safety Act

From Rep. Mike Thompson’s website
[Editor:  Read the bill on Rep. McDermott’s website.  Track the bill on GovTrac.us.   Authenticated version of the bill is here.    HIGHLY SIGNIFICANT:  Sec. 4. Requires the Secretary of Transportation to immediately prohibit the shipment of oil in all DOT-111 tank cars, and unjacketed CPC-1232 cars.  Allows jacketed CPC-1232 cars to remain in service.  Requires the Secretary of Transportation to prohibit, after 2 years, the shipment of ethanol in all DOT-111 tank cars, and unjacketed CPC-1232 cars.  Allows jacketed CPC-1232 cars to remain in service.  – RS]

THOMPSON INTRODUCES CRUDE-BY-RAIL SAFETY ACT

Apr 15, 2015, Press Release

WASHINGTON, D.C. – U.S. Rep. Mike Thompson (CA-5) today co-authored and introduced the Crude-by-Rail Safety Act which establishes comprehensive new safety and security standards for the transport of crude oil by rail. The legislation is designed to help protect communities along the nation’s railway networks. The legislation comes amid growing concerns that current standards do not address the threat posed by transporting crude oil by rail. Representatives Jim McDermott (WA-7), Doris Matsui (CA-6) and Ron Kind (WI-3), and Nita Lowey (NY-17) introduced the legislation with Thompson.

“Public safety is priority number one when it comes to transporting highly volatile crude oil,” said Thompson. “Railcars transporting crude run through the heart of our communities, and as recent accidents have demonstrated, robust, comprehensive action is needed. The bill introduced today  puts safety measures in place that will help make sure communities are secure, railcars are as strong as possible, and first responders are prepared in the event of an emergency.”

In recent months, the large growth in crude-by-rail transport has led to increased rail traffic and a rise in rail accidents. Four derailments in the US and Canada in under a month earlier this year underscored the urgency of action to curb the risks of transporting volatile crude oil. The legislation introduced today will increase safety standards and accountability.

The Crude-by-Rail Safety Act would establish new, commonsense federal safety standards for railcars transporting oil across the country.  This legislation:

  • Establishes a maximum volatility standard for crude oil (propane, butane, methane, and ethane) transported by rail
  • Prohibits use of unsafe DOT-111 tank cars, including the removal of 37,700 unsafe cars off the rail network
  • Establishes the strongest tank car standards to-date
  • Requires comprehensive oil spill response planning and studies
  • Increases fines for violating volatility standards and hazmat transport standards
  • Requires disclosure of train movements through communities and emergency response plans
  • Requires railroads to implement a confidential close-call reporting systems

Congressman Mike Thompson is proud to represent California’s 5th Congressional District, which includes all or part of Contra Costa, Lake, Napa, Solano and Sonoma Counties.  He is a senior member of the House Ways and Means Committee. Rep. Thompson is also a member of the fiscally conservative Blue Dog Coalition and chairs the bipartisan, bicameral Congressional Wine Caucus.

Academic: Technology can make Crude By Rail safer

Repost from The Conversation US, Boston
[Editor:  On this page I present TWO articles by Bryan W Schlake, Instructor in Rail Transportation Engineering at Penn State Altoona and a former employee of Norfolk Southern Railway.  The first, directly below, explores crude-by-rail risks and seems overly sympathetic to the rail industry.  The second more interesting and informative article, farther below (click here) explores ways to improve crude-by-rail safety.  – RS]

Despite disasters, oil-by-rail transport is getting safer

By Bryan W Schlake, April 14 2015, 5.48am EDT
This derailed oil-carrying train in Ontario in March was the third from a single freight company in a month. Reuters

For many Americans, railroad transportation rarely appears on our mental radar, and when it does, it often comes with a negative context: either we are stopped at a railroad crossing while running late for work or we come across a news article with shocking images of smoke and flames accompanied by reports of exploding tank cars.

Months go by with no thought of railroad transportation, until another derailment occurs, and we again associate trains with fire and danger.

With US crude oil production nearing all-time highs – averaging over 8.5 million barrels per day in 2014 – many are expressing fears about the potential of a crude oil spill in their community. And last week, the National Transportation Safety Board released “urgent” recommendations to promote the safety of shipping crude oil, ethanol and other flammable materials by rail.

What’s behind this rapid rise in oil-by-rail transport? How dangerous is it and can new technology make it safer? To answer these questions, we’ve prepared two articles on transporting oil by rail in the US. The first explores the economic drivers and assesses the rail industry’s record on safety; the second evaluates the technology, research and railroad operating practices that can lead to the greatest level of public good.

By better understanding the underlying issues, we can have a meaningful dialogue and take action towards the common goals of improved safety, security and economic stability.

Economics of oil by rail

Oil production in the US is booming. Last year, for the first time since 1987, annual US field production of crude oil topped three billion barrels, a 170% increase since 2008.

Technological advances such as hydraulic fracturing, or “fracking,” and horizontal drilling allowed for increased production, notably in the Bakken formation in North Dakota. But rail has been integral to the domestic oil surge. It was the availability of low-priced, flexible transportation that allowed crude oil to be shipped to US coastal refineries, creating the market for Bakken oil.

As pipelines quickly reached capacity, oil shippers turned to the railroads, which provided multiple incentives, including: flexibility in shipping options and contract timelines, shorter transit times to the refineries (five to seven days by rail compared with 40 days by pipeline), and the ability to choose which refineries to use. While pipelines allow for higher volumes to be transported, the higher speed afforded by rail results in reduced transit time for long distances.

Association of American Railroads, Author provided | Click to enlarge

As a result, Bakken oil production increased from 81,000 barrels per day in 2003 to more than one million barrels by mid-2014, with more than three-quarters of those barrels moving daily out of North Dakota by rail. While carloads of crude oil increased dramatically, on the whole it still comprises a relatively small portion of total railroad shipments – only about 1.6% of all carloads for US Class I railroads.

Because of increased domestic production and increased imports from Canada, 66% of US oil demand is now sourced from North America, a shift that’s lowered imports and will create billions of dollars in economic activity over the next several decades.

Assessing the risk

While there exists no universally accepted definition of risk, it is widely accepted that the risk associated with transportation of hazardous materials must factor in both the probability of a release of the hazardous material as well as the magnitude of the consequences of that release.

Statistically, the probability of an oil train derailment is very low and lower than other forms of transportation (see figure, below). But the potential undesirable consequences are relatively high, including damage to human life, property and the environment.

A worst-case scenario occurred in the Lac-Mégantic accident of 2013 in Canada, which resulted in 47 fatalities, another 2,000 people evacuated from their homes, almost 1.6 million gallons of crude oil released and millions of dollars in property damage.

Author provided | Click to enlarge

Since 2013, three other notable oil train derailments have occurred in Canada, including recent derailments in Ontario, and seven in the US, including the recent derailments in West Virginia in February and Illinois in March. Using data available from the FRA Office of Safety Analysis, here is a summary of statistics for US crude oil train derailments from 2013 to 2014:

  • eight derailments were reported involving a crude oil release
  • two of these derailments resulted in a release exceeding 450,000 gallons
  • two of these derailments resulted in a release between 15,000 and 30,000 gallons
  • the remaining four derailments resulted in a release of 5,000 gallons or less
  • injuries were reported in only two derailments, resulting in four total injuries
  • no fatalities were reported in any derailment
  • people were evacuated in three of these derailments, with the number of people affected ranging from 16 to about 1,000 people
  • track and equipment damage exceeded $1 million for all derailments, with only one derailment resulting in more than $5 million in damages (damage to private property or depreciation of property values not included).

In terms of hazardous materials risk, the consequence to human life was very low in these US incidents, with zero fatalities and only four reported injuries.

Bigger spills

Environmental and economic impacts, however, were substantial. Recent reports have noted that the amount of oil spilled in 2013 alone from train derailments, at more than 1.1 million gallons, was greater than the total amount of oil spilled from 1975 to 2012. As demand for crude oil shipments has increased, railroads have shifted to using “unit trains” in which nearly every car carries oil instead of the variety of railcar types found on a manifest train. For unit oil trains, the only cars that are not tank cars are the “buffer cars”, typically located in the front and rear of the train to provide an added level of safety for the train crew in the event of an accident.

The use of unit oil trains has resulted in larger amounts of oil being spilled in a single derailment. For example, the majority of oil released in 2013 resulted from only two derailments, occurring in Aliceville, Alabama, in November of 2013 and Casselton, North Dakota, in December of 2013. The recent accident in West Virginia on February 16 of this year likely resulted in a release of similar magnitude to the 2013 spills. The accident in Galena, Illinois on March 5th of this year resulted in a spill of over 200,000 gallons of crude oil released from seven tank cars.

Author provided

The other side of the coin for risk assessment is the probability of release, which is extremely low when compared with other transportation modes. In 2013, which was the worst year to-date for oil train derailments, about 28,000 barrels of oil were released from railroad tank cars out of the approximately 300 million barrels of oil delivered by rail.

In other words, less than one hundredth of 1% of the volume of oil transported by rail in 2013 in the US was released into the environment. According to an analysis of US oil spillage, the amount of oil spilled by railroads per billion ton-mile transported declined by approximately 85% throughout the 1990s and 2000s. By comparison, pipelines experienced closer to a 40% decline in oil spilled per billion ton-miles over the same period. While this report does not include the recent increase in unit oil trains, it does provide a valuable comparison across transportation modes.

Due to changes in safety culture and numerous technological advances, railroads have continued to improve safety over the last decade, with accident rates reaching all-time lows in 2014 at only 2.24 train accidents per million train miles. The industry has been clear about its goal to continue to use new technologies and improved operating practices to drive accident rates even lower, asserting that “No accident, big or small, is acceptable.”

In our next piece [below], we’ll look at some technologies that can improve safety.


PART II …

Repost from The Conversation US, Boston

Shipping oil by rail is booming. Technology can make it safer

By Bryan W Schlake, April 15 2015, 6.18am EDT
The National Transportation Safety Board made an ‘urgent’ recommendation to improve the safety of oil-carrying rail cars. Rick Wilking/Reuters

The Energy Information Administration recently released a map that reflects a massive change to our economy few people appreciate.

The graphic, shown below, shows the latest data on crude oil-by-rail movements around the country and the surge in oil shipments from North Dakota to the different corners of the country. Last year, trains transported more than one million barrels of oil per day in 2014 – a huge jump from 55,000 barrels per day in 2010.

Energy Information Administration | Click to enlarge

This increase in oil-by-rail transportation has come with a number of high-profile derailments, including an accident in Illinois just last month, which have caused substantial economic and environmental damage. Can technology improve safety? Yes. In much the way automobiles are becoming increasingly high-tech, various stakeholders in rail transportation are exploring various technologies to improve safety.

Building a better rail car (and maintaining it)

Railroads have already taken some steps to improve equipment with better braking systems and upgrades to the track infrastructure. New practices can improve safety as well, including better track inspections, speed restrictions for oil trains and choosing routes to reduce exposure to population centers. Railroads have also increased the use of freight car defect detectors installed alongside the the tracks that automatically identify mechanical defects on the railcars based on force, temperature, sound, or visual measurements.

The industry standard needs to be improved, say safety officials, but it’s unclear who will pay for upgrades. Roy Luck, CC BY | Click to enlarge

Many of these technologies are already being implemented by the railroads both to improve safety and to increase economic benefits. In addition to minimizing the safety risk associated with derailments, improved track and vehicle inspection practices help to reduce the potential for delays, which can cost railroads hundreds of dollars per hour.

An economic analysis from 2011 estimated that the annual train delay costs due to railcar defects (resulting in trains stopping unexpectedly enroute) was over US$15 million for all US Class I railroads. For comparison, each year the four largest US Class I railroads spend an average of $35 million on track and equipment damages due to main-line derailments. Thus, the economic drivers behind the reduction of derailments and train delays are quite substantial.

Federal agencies and lawmakers are also working to ensure that federal safety requirements and public policy address the new transportation landscape resulting from the domestic oil boom and increased imports from Canada. The federal government is currently considering new safety standards for improved tank cars specifically designed for the transportation of crude oil.

However, movement towards such legislation has presented considerable challenges due to the fact that the vast majority of tank cars are owned by private companies other than the railroads that transport them.

As a result, questions arise regarding who should bear the economic burden of replacing and/or retrofitting the crude oil tank car fleet. Due to safety and economic incentives mentioned above, some railroads have already begun to purchase their own improved tank cars, but this has not become a universal trend across the industry.

Role of research

Researchers, too, are exploring how technology can improve safety in a variety of ways, including:

Improved Tank Car Design: The Association of American Railroads (AAR) is working to promote tougher federal standards for tank cars carrying crude oil and other hazardous liquids. Extensive research is ongoing both within the Federal Railroad Administration and at various universities to assess tank car safety and develop an optimized tank car design: Cooperative Research in Tank Car Safety Design.

Acoustic bearing detectors, the white-colored machines on either side of the tracks, take sound measurements which allow railroads to predict when railcar roller bearings are beginning to wear out. Bryan Schlake, Author provided | Click to enlarge

Track and Infrastructure Inspection: Railroad track failures have been found to be a leading derailment cause in the US. As a result, railroads have begun to perform more track inspections, including the use of advanced track geometry vehicles – which use laser systems to measure the profile of the rail – on routes carrying crude oil trains. Ultrasonic rail inspection methods as well as ground-penetrating radar systems are also being developed to improve the ability of railroads to detect track defects.

Risk Assessment: Railroad transportation risk research associated with hazardous materials is ongoing. Risk assessment has included rail defect inspection, evaluating routing and train speed, track quality and an integrated framework to reduce risk. This framework addresses operating practices, train routing, infrastructure, and car design to identify the financial and safety risk associated with hazardous materials transport by rail.

Automated Condition Monitoring Technologies: Various wayside detector systems have been developed and installed across the country at locations adjacent to track to assess the condition of locomotive and freight car components enroute. These systems incorporate various technologies to identify critical defects resulting in both safety and economic benefits. Some key technologies include:

  • infrared temperature sensors used to measure overheated wheels/bearings
  • accoustic bearing detectors to identify worn roller bearings in railcars
    High-tech rail: a closer look at an acoustic bearing detector. Bryan Schlake, Author provided | Click to enlarge
  • laser systems to measure wheel profiles and identify worn wheels
  • machine vision systems to detect low air-hoses, structural defects and broken or missing railcar safety appliances
  • load impact sensors to identify damaged wheels that are out-of-round or exhibit flat spots.

Advanced Braking Systems: Both technology and operating practices can play a role in improving braking for oil trains. Some have suggested the use of Electronically Controlled Pneumatic (ECP) brakes. ECP brakes allow for faster application of the brakes on all cars in a train using an electric signal, instead of an air signal, to initiate a brake application.

ECP brakes have been used on a limited basis for coal trains, but the costs have not been proven to justify the safety and economic benefits. A better option may be the use of either:

  1. distributed power, where locomotives are dispersed throughout the train (i.e. front, rear and even in the center) and/or
  2. two-way end-of-train devices (EOTD) that allow brake signals to be initiated from the rear of the train.

Both of these operating practices result in faster braking and reduce “run-in”, where the cars in the front of the train begin braking before those on the rear, causing the rear cars to “run-into” the cars in front of them, creating higher in-train forces. After these measures were proposed by the US Department of Transportation in July of 2014, US Class I railroads agreed to implement enhanced braking in the form of distributed power or two-way EOTDs on all oil trains.

A derailment in Lynchburg, Virginia in 2014 emptied at least one car’s load of crude into the James River Waterkeeper Alliance Inc., CC BY-NC-ND | Click to enlarge

Positive Train Control (PTC): This technology will automatically slow or stop a train to prevent a collision or derailment due to human error, such as speeding or missing a signal. After a federal mandate in 2008, railroads have begun to develop and install this GPS-based safety overlay system, which will eventually cover more than 60,000 miles of track in the US.

Emergency Response: Railroads are working together with various organizations to improve community safety through emergency response training.

Reducing risk

In addition, new technologies are being developed to improve the speed and effectiveness of environmental cleanup efforts. For example, researchers at Penn State University have developed a patented technology called Petro-SAP to absorb oil from the environment after a spill. Technologies like this can be used in the future to mitigate environmental impact of train related oil spills.

While the risk associated with oil train derailments has not been eliminated, the transportation of crude oil by rail has certainly become safer through extensive research, development and implementation of new technologies.

Continued efforts by railroads, government agencies, research institutions and universities will continue to improve the safety of crude oil transportation by rail, reducing risk and potentially alleviating public fears associated with railroad transportation.

November train derailment in Feather River Canyon caused by broken rail

Repost from The Chico Enterprise-Record

November train derailment in Feather River Canyon caused by broken rail

By Ashley Gebb, 04/13/15, 5:11 PM PDT
Twelve rail cars full of corn derailed Nov. 25 in the Feather River Canyon. The accident was caused by a broken rail. Courtesy of Jake Miille
No railroad cars reached the Feather River after the Nov. 25 derailment, but corn did. Courtesy of Jake Miille

Belden >> A November train derailment in the Feather River Canyon was caused by a broken rail, the Enterprise-Record has learned.

As Union Pacific Railroad prepares to replace more than 36 miles of track between Keddie and Lake Oroville, spokesman Francisco Castillo has confirmed a detail fracture caused by cracks led to the derailment of 12 train cars that tumbled into the canyon Nov. 25. The repairs are unrelated and were planned before the accident, Castillo said, part of a greater effort to improve rail safety as transport of crude oil continues to rise.

“Though serious accidents are rare, we recognize that there are still risks associated with rail transportation, just as there are risks with any other mode of transportation. That’s why we follow strict safety practices and work tirelessly to achieve our goal of zero derailments,” he said in an email.

In the early morning of Nov. 25, a westbound train derailed near Virgilia, upstream of Belden, causing 12 loaded hoppers to slide down an embankment toward the North Fork Feather River below, stopping just before the water. No one was injured but the carloads of corn were spread across the hillside and into the river, causing $640,049 in equipment damage and $85,786 in damage to the track.

At the time, emergency officials said the incident underscored the risks associated with train transport in the canyon.

“It’s a concern for us because it shows there is still a history of derailments in the county, especially in the canyon,” Butte County Emergency Services Officer John Gulserian said Monday of the November derailment.

Though the incident occurred in Plumas County, the same railroad lines continue into Butte County, along with whatever the trains are hauling — be it corn or crude oil. The derailment of any such materials can have devastating implications for the water, the environment and wildlife, as well as create a fire danger, Gulserian said.

Because of the remote area and the nature of the spills, the county is not always equipped to deal with the accident and has to wait for other resources, he said.

The canyon area as a whole tends to see a derailment every three to five years, with most similar to the November incident, where only a few cars go off the tracks, he said. The last derailment Gulserian could remember spilled a load of neutralized alcohol near Storrie.

Track failures are linked to 31 percent of all train accidents, and even though such incidents are becoming less common, prevention remains critical, said Federal Railroad Administration spokesman Mike Booth. It’s especially important with a 400 percent increase in more volatile Bakken crude oil being shipped out of the North Dakota region.

“It travels to nearly every state and it travels long distances,” he said. “To prevent accidents due to increased traffic going longer distances, we have increased inspection on crude oil routes. … Since the Lac-Mégantic accident two years ago in Canada, it was a bit of a wake-up call for everyone.”

The 2013 incident occurred when a 74-car freight train carrying crude oil derailed, resulting in a fire and explosion of multiple tank cars. Forty-seven people were killed, and dozens of buildings were destroyed or critically contaminated.

Railroads are required by law to inspect and maintain their equipment in good repair, and the Federal Railroad Administration ensures that by auditing records and doing spot inspections, Booth said. It also works with the Department of Transportation and the Pipeline and Hazardous Material Safety Administration, which has taken more than two dozen actions to increase the safety of crude oil transport.

“And we are looking for more ways to make it even safer,” Booth said. “We don’t want to have a single derailment …”

In the past 10 years, Castillo said derailments have decreased 38 percent, largely in part to a derailment and risk reduction process, which includes using lasers and ultrasound to identify rail imperfections, tracking acoustic vibration on wheels to anticipate failures before they happen, and performing real-time analysis of every rail car via trackside sensors. Employees also participate in rigorous, regular safety training programs that include the identification and prevention of derailments, and Union Pacific trains first responders on ways to minimize the impact of derailment in their communities.

Track maintenance projects are part of Union Pacific’s annual maintenance work and scheduled three to five years in advance, Castillo said. From 2005-14, the railroad invested more than $31 billion in its network and operations to support the transportation infrastructure, and it is in the middle of $26.1 million in improvements in the Feather River Canyon area.

The first project is complete and included replacement of 15.2 miles of rail just east of Oroville. The second project, scheduled to begin next month and be complete in August, will replace 36.3 miles of rail at various locations between Keddie and Lake Oroville.

“The Feather River Canyon upgrades will enhance the safe transport of commodities we transport through the canyon,” Castillo said.

Union Pacific and other entities have been working with Butte County recently to improve safety, Gulserian said. That effort included an exercise March 11 with a simulated train derailment near Chico that provided the opportunity to practice alert notifications, areas of authority, staging materials and alerting the public. Another simulation has been scheduled.

Gulserian said it’s encouraging to hear news of rail replacement, as safety and security of hazardous materials is as much a priority for the county as it is for the railroad.

 

Federal, state and local officials gather in Davis California to discuss oil train safety legislation

Repost from The Vallejo Times-Herald
[Editor:  Thanks to Rep. Garamendi for his sponsorship of HR1679 to require Bakken oil stabilization before it is loaded onto oil trains.  But you can add Garamendi’s name to the long list of officials who show little interest in stopping bomb trains, who operate under the illusion that “safer” is ok.  Quote: “He added that the push isn’t to stop transportation of oil by rail, but to make it safer….”  – RS]

Crude oil-by-rail safety focus of proposed bill

By Melissa Murphy, 04/08/15, 10:05 PM PDT
U.S. Congressman John Garamendi, D-Solano, pauses as a freight train passes during a press conference at the Davis Amtrak Depot on Wednesday to highlight the need for state and federal action to improve the safety of crude oil-by-rail transports. Joel Rosenbaum — The Reporter
Solano County Supervisor Skip Thomson expresses his concerns about rail safety as he participates in a press conference on the issue Wednesday in Davis. Joel Rosenbaum — The Reporter

Transportation of crude oil by rail was a hot topic Wednesday as federal, state and local government officials gathered at the train depot in the city of Davis.

Congressman John Garamendi, D-Solano, addressed media during a press conference about his legislation, H.R. 1679, which would prohibit the transport of crude-by-rail unless authorities have reduced the volatile gases in the oil prior to transportation.

Specifically, maximum Reid vapor pressure of 9.5 psi, the maximum volatility permitted by the New York Mercantile Exchange for crude oil futures contracts.

“Further analysis and debate is warranted, and H.R. 1679 is intended to move debate forward and stress the urgency of action before more lives are needlessly lost,” Garamendi said. “It doesn’t have to be explosive.”

He added that the push isn’t to stop transportation of oil by rail, but to make it safer and that the federal government needs to get its “train in gear” to adopt regulations.

Sarah Feinberg, acting administrator of the Federal Railroad Administration, said even though the issue is complicated, they’re working on a comprehensive approach.

She explained that there has been a 4,000 percent increase in the amount of crude by rail. It continues to be transported by rail, pipeline and truck.

While it will take a long time to create and pass new regulations and standards, interim steps have been taken, including additional emergency regulations, speed reductions, increased inspections and more emergency equipment.

“We’ll continue to do more,” she said.

Standing next to photos of two fiery oil car train explosion, one that occurred as recently as February in West Virginia, Davis Mayor Dan Wolk said the trains go through the heart of the city, and there is a high risk if crude-by-rail starts moving through the corridor.

“It could have catastrophic effects in our community,” he said. “Garamendi’s legislation is in perfect alignment with city objectives. Safety is the priority.”

Solano County Supervisor Skip Thomson agreed and added that the legislation needs to be passed as soon as possible.

Other steps have been taken by the California Office of Emergency Services.

Eric Lamoureux, inland regional administrator for OES, said six hazardous materials vehicles stand ready to respond throughout the state and within the next few months local exercises will test the systems and procedures in place.

Lamoureaux also explained that explosions are a concern, but there also is a risk to water supply. He shared that a derailment in November sent eight train cars and loads of corn into Feather River Canyon near Lake Oroville.

He added that it could have been a bigger issue if it was crude oil.

Garamendi also explained that the process of removing volatile gases isn’t new, but a regular standard for refineries in Texas.

Meanwhile, the city of Benicia is considering an application that would allow Valero Refinery to receive and process more crude oil delivered by rail. The proposed crude by rail project would be a third means to deliver crude oil. So far, Valero receives the crude oil by marine deliveries and pipeline.

According to the city of Benicia website, the city has determined that sections of the Draft Environmental Impact Report, when it comes to the Valero project, will need to be updated and recirculated. The anticipated release of the Recirculated Draft EIR for public comment is June 30. The Recirculated Draft EIR will have a 45-day comment period. After the comment period on the Recirculated DEIR closes, the city will complete the Final EIR which will include responses to all comments on the original Draft EIR and the Recirculated Draft EIR.